Free Traffic Legal Advice

My partner parked at Oradent Ashford private car park on 03/01/20 25.  The terminal for number plate entry was out of service due to a power fault in the building so our vehicle details were left with the staff on the desk at Oradent to pass on to the parking operator.  The Manager at Oradent informed the operator, Creative Car Park Ltd (CCP) / Civil Enforcement Ltd (CE) that the terminal was out of service and was told by the CCP customer service agent that a 'black out' would be put in place for the day, which I assume means no PCNs would be issued on the day based on the registration being missing from the number plate registration terminal data.

To be clear, there was no parking contravention, we were legitimate customers and our vehicle details were passed to the staff on the desk at Oradent.

To my surprise, I received a PCN through the post addressed to me as registered keeper.  I passed the letter to my partner as she was the driver and she phoned Oradent, the owners of the car park, who informed her that it would be dealt with it.

I assumed all would be fine as 2 previous PCNs issued in similar circumstances by Parking Eye had been successfully cancelled following a phone call to the car park owner who had then called the parking operator (Parking Eye in the other cases) and arranged for the PCN to be cancelled.

So the appeal window expired while I was thinking it had all been dealt with following the call to the manager at Oradent.

A reminder was received end of January / early February which I again passed to my partner, who made a further call to  the manager at Oradent, 13/02/2025 followed by a letter from the debt collector (DCBL Ltd) dated 7th March.

I've seen extracts from the email conversation between the Oradent manager and customer services and CCP Ltd so I know that CCP were informed of the terminal fault, I've also seen extracts from an email sent to CCP by the Oradent Manager informing them that we have received a PCN when we shouldn't have.

The appeal window has now closed I don't seem to have any way to speak to anyone about this.  Oradent have contacted CCP again and been told that they can't do anything as its been sent to debt recovery (DCBL) I've spoken to DCBL who have said that to cancel the PCN they require an email from CCP requesting that the PCN be cancelled.  I can't go to POPLA as I have no appeal rejection reference from CCP.

Just seems to be impossible to talk to anyone about this.  I've emailed CCP complaints department and their customer services email address which was passed to me by the manager at Oradent and I've not received a reply to either.

I've no idea what happens next, other than a County Court summons.  I've never been to court, have no idea how to prepare and absolutely no desire to pay a solicitor to deal with this madness.

Any advice greatly appreciated.

Thanks for the advice, all very helpful.  Civil Enforcement Ltd definitely act on behalf of Creative Car Park Ltd - this taken from the Creative Car Parks Ltd website:

* Source: POPLA annual report 2023. Note, Civil Enforcement Ltd operates on behalf of Creative Car Park Ltd 

Email correspondance Oradent shared with me is between Oradent and Creative Car Park Ltd.  I was provided with a Creative Car Park email address by Oradent and made a complaint via that email address, customerservice@creativecarpark.co.uk.  I've not received a reply.

All PCN letters have been recieved from Civil Enforcement Ltd and refer to the Oradent car park at the Ashford address.

Something is not right about all this. CCP and CEL are two separate companies, each registered separately with Companies House. The contract allegedly breached by the driver is with CCP. CEL are not a party to that contract. Just like any powerless debt collector cannot initiate any action, neither can CEL, whether they are "acting on their behalf" or not.

Please show us the correspondence that we are discussing here as something smells rotten. You have not shown us the Notice to Keeper (NtK) both sides please. Can you provide any photos of the signage at the location?

This is all to do with civil contract law and this intermixing of different companies over an alleged contract breach, requires investigation. Without showing us the evidence (suitably redacted of your personal details) is not going to enable us to assist you properly.

Considering that the powerless DCBL have been engaged, means that they are likely to use DCB Legal to issue any claim on their behalf. I can say with greater than 99% confidence that any claim issued by DCB Legal will be discontinued, no matter how feeble the defence.

PCN attached

[ Guests cannot view attachments ]

And what parking operators name is on the signs that contain the terms and conditions of parking (the contract)?

Whilst CEL may "act on behalf of CCP", the invoice is from CEL. If the name of the operator on the signs is not CEL, then there is an issue. CCP is not a trading name of CEL. CCP is a separate registered company.

That still does not clarify what CCP have to do with an invoice from CEL if the contract is with CEL. Simply stating that CEL are acting for CCP is not an answer. If CCP were a trading name of CEL, that would be a different matter but that isn't the case as CCP are an independently registered limited liability company.

Something here doesn’t add up, and the whole situation smells bad.

According to the Notice to Keeper (NtK), it was Civil Enforcement Ltd (CEL) who obtained the Keeper’s personal data from the DVLA and named themselves as the “creditor.” That means CEL are claiming to have the legal right to issue and enforce the parking charge. Only the company with a valid contract from the landowner has that right, or someone authorised by them.

However, all communication from the landowner (Oradent) is with Creative Car Park Ltd (CCP) – a completely separate company from CEL. There is no communication at all between Oradent and CEL. So the question is: why did CEL access the Keeper’s DVLA data if Oradent are dealing with a different company (CCP)? If CEL do not have their own contract with Oradent, they had no lawful reason to get the Keeper’s personal details.

Under GDPR, any company accessing and using personal data must have a legal basis to do so. The usual basis in these parking cases is called “legitimate interest.” But that only applies if the company has a real interest and legal reason to act – such as being the contracted operator. If CEL does not have a contract with Oradent, they may will have accessed the Keeper’s DVLA data unlawfully.

There is another problem. Oradent clearly believes that CCP are handling the parking enforcement. Oradent passed the Keeper’s personal data to CCP to deal with the matter. But if CEL are the creditor and CEL got the data from the DVLA, why does CCP have any access to that data at all? The Keeper did not give permission for CCP to have their details, and CCP is not named on the NtK. If CCP are not the data controller, they have received the Keeper’s data unlawfully from Oradent or CEL.

It gets worse. CCP appear to know that the case has been passed to a debt collector (DCBL). That means either CEL shared the Keeper’s data with CCP, or CCP shared it with CEL, or Oradent shared it with both. In any of those cases, there has been data sharing between separate companies, and it is unclear if any of that sharing was lawful or agreed.

As for DCBL – they are not a party to the alleged contract. If a contract existed, it would be between the driver and either CCP or CEL – not both, and definitely not DCBL. There can’t be a single contract with both CCP and CEL. Only one company can hold the rights under the contract, not both at the same time.

You absolutely must not communicate with DCBL. They are powerless to do anything as they are not a party to any contract allegedly breached by the driver. Never, ever, communicate with a useless debt collector, especially DCBL. Ignore them.

So the GDPR issues are:


All of this creates a very confusing and probably unlawful chain of data handling.

These are the suggested next steps:

1. Do not communicate with DCBL.

This remains unchanged. DCBL are irrelevant. They are not a party to any alleged contract and cannot enforce anything. No replies, no engagement. Ignore them entirely.

2. Send a letter to Oradent.

Use the draft response below to put responsibility back on Oradent as land occupier. They are the party who contracted with CCP and/or CEL and are therefore jointly and severally liable for any data misuse, signage failings, or enforcement actions. This makes it clear that the matter is not closed and that you, the Keeper, will not be passed from pillar to post.

3. Hold off on contacting CEL or CCP for now.

Since the PCN was issued by CEL but all communication from Oradent has been with CCP, it's unclear who is truly responsible. Let Oradent clarify who they contracted with and who they instructed. If they fail to provide clarity or take responsibility, further action can then be taken directly with the parties involved.

4. Gather evidence from the site.

You should still return to the car park and:


This step is important in case a formal complaint needs to be escalated or if legal action is later brought.

5. Keep all communications and evidence organised.

Retain copies of:


6. Await response from Oradent before further escalation.

Only once Oradent have replied (or failed to do so within a reasonable time) should you consider:


Here is a draft letter you should sent to your contact at Oradent:

Dear [Oradent Practice Manager/Reception],

Thank you for sending over the emails between your practice and Creative Car Park Ltd (CCP). However, I must make it clear that your response is not satisfactory, and I do not accept that this matter has been resolved by asking me to “deal with DCBL.”

To be clear:

1. The PCN (Notice to Keeper) was issued by Civil Enforcement Ltd (CEL), not CCP.
2. All of your communication has been with CCP, not CEL.
3. CEL and CCP are entirely separate companies. They are not trading names of one another.
4. There has been no communication between CEL and yourselves, and yet CEL claim to be the "creditor" in this matter and have obtained and processed my personal data, which raises serious concerns under data protection law.
5. I have never given consent for you to pass my personal information to CCP or CEL, or for it to be shared between them.
6. Despite being informed of the blackout, a PCN was issued. You then confirmed the vehicle was legitimately on site. CCP acknowledged the issue and agreed a “blackout” was applied — meaning no PCNs should have been issued. Yet the PCN has still been escalated to a debt collector.

I must also make it clear that I will not communicate with DCBL, who are not a party to any alleged contract and have no legal standing. They are irrelevant to this matter and their letters will be ignored.

As the land occupier and party who engaged the services of the parking operator (CCP or CEL), you are jointly and severally liable for the actions of any company you have authorised to enforce parking on the land. That includes the wrongful issue of charges, any unlawful sharing of personal data, and the ongoing harassment caused by debt recovery action.

I now require you to:

• Immediately escalate this matter to senior management within Oradent or your head office.
• Instruct CEL or CCP, whichever is responsible, to cancel the charge and to recall the matter from debt recovery.
• Confirm what contractual arrangements exist between Oradent, CCP, and CEL that have led to this confusion and the wrongful issue of a PCN.
• Explain why my data was shared or accessed by these companies without clarity or transparency.

If this matter is not resolved swiftly, I will have no choice but to consider a formal complaint to the Information Commissioner’s Office (ICO) and the DVLA, as well as exploring other avenues to recover any loss or distress caused.

I trust you will treat this matter with the urgency it deserves.

Yours sincerely,

[Keepers name]

Oradent car park additional notices

[ Guests cannot view attachments ]

The signs at the Oradent Ashford car park clearly state that Civil Enforcement Ltd (CEL) is the parking operator. Both signs name CEL directly and include their contact details, website, and company number. One of the signs even says the site is “managed using ANPR and manual patrols by Civil Enforcement Ltd.”

So according to the signs, CEL are the company offering the parking contract to drivers, enforcing the rules, and obtaining DVLA data. There is no mention at all of Creative Car Park Ltd (CCP) on any of the signs.

This completely contradicts what the Oradent staff have said — they claim they only deal with CCP and have no involvement with CEL. They also said that the matter was reported to CCP and that CCP applied a “blackout.” This suggests the landowner’s agreement is with CCP, not CEL.

If CEL are not the company contracted by Oradent, then:


At the same time, if Oradent's head office operations team has a centralised contract with CEL but the local staff mistakenly believe they deal with CCP, that’s a serious internal miscommunication. It may also explain why the wrong company (CCP) told Oradent they would apply a “blackout,” but had no actual control over the PCN issued by CEL.

To be clear:


This now strengthens the position that:


This also increases the seriousness of the issue from a data protection and consumer law perspective.

As already stated, you should not communicate with DCBL under any circumstances.

Here is an updated letter you should now send to Oradent without delay:

Dear [Practice Manager / Oradent Head Office],

Following your recent response and the correspondence you shared between yourselves and Creative Car Park Ltd (CCP), I have since visited the Oradent Ashford car park and inspected the signage on site.

The signs clearly and repeatedly state that the car park is managed and enforced by Civil Enforcement Ltd (CEL). CEL is named on the signs as the party responsible for using ANPR and manual patrols, issuing parking charges, and contacting the DVLA. There is no mention whatsoever of Creative Car Park Ltd (CCP) anywhere on the signage.

This raises serious concerns.

You told me that your staff have no direct dealings with CEL and that they only deal with CCP. You also shared emails between your staff and CCP in which CCP acknowledged a fault with the terminal on 3 January 2025 and confirmed a “blackout” was applied, meaning no charges should have been issued. Yet the Notice to Keeper I received was issued by CEL – a completely different company.

As the Registered Keeper who has received the PCN, I am entitled to know who actually manages parking enforcement at this location. CEL and CCP are two separate legal entities. A driver cannot be in a contract with both of them at the same time, and only the company with a valid agreement flowing from the landowner has the authority to issue parking charges.

If CCP are the company you have contracted with, then CEL have:

• Accessed my personal data from the DVLA unlawfully
• Issued a parking charge with no legal authority
• Created serious confusion about who holds liability for this matter

If CEL are the company with the contract, then why were your staff communicating only with CCP, and why was a “blackout” agreed by a company with no apparent role in enforcement?

The situation is now completely unsatisfactory. You have passed this matter back to me and wrongly suggested that I deal with DCBL, a powerless third-party debt collector with no standing or authority. I will not be engaging with DCBL under any circumstances. They are not a party to any alleged contract and are entirely irrelevant.

As the occupier and party who appointed the parking enforcement company, you are jointly and severally liable for any data misuse, confusion, or enforcement action taken by the companies acting under your instruction. You cannot avoid that responsibility by referring me to a debt collector or stating that the matter is out of your hands.

I now require the following:

1. Confirmation of the full legal name of the company currently contracted to manage and enforce parking at the Ashford site
2. Confirmation of whether CEL were authorised to issue a parking charge in this case
3. An explanation of why your staff are dealing only with CCP, despite all signage referring exclusively to CEL
4. Written confirmation that the PCN will be cancelled immediately
5. Confirmation that CEL and/or CCP have been instructed to recall the matter from DCBL

If I do not receive a satisfactory response, I will escalate this matter as a formal complaint to:

• The Information Commissioner’s Office (ICO), due to the potential unlawful processing and sharing of my personal data
• The DVLA, as there is reason to believe that my data has been obtained and used without a proper legal basis

If it is shown that my personal data has been obtained and/or used unlawfully, I will hold all parties involved fully liable for breach of my rights under the UK GDPR and the Data Protection Act 2018, and I reserve the right to pursue a claim for damages and any other remedies available.

Please escalate this to your Head Office or regional operations team immediately. I expect a full and clear response without delay.

Yours sincerely,

[The Keeper’s name]